Subject: File No. S7-07-13
From: Chris Corayer

We need to assign simple, easy to follow rules that are not open to interpretation with regards to reporting CEO pay. It should be simple and not subject to rules lawyering and loopholes.

ALL compensation should shown including any perks, stocks, bonds, etc.

All employees and the numbers of them should be included when calculating. An exception could be made for unpaid interns and volunteers but if they are a sizeable portion of the workforce they should included in the calculation. Perhaps with a x% of the workforce is unpaid. I feel there should also be a breakdown of part time % and full time % of the workforce along with the ratio of Executive compensation to those numbers. In the case of part time pay, the median number of hours worked should be used so as not to inflate any numbers unfairly. If all part timers only are allowed to work 28.5 hours so as to skirt the Affordable Care Act, then those absolute numbers should be used instead of stating 8.25$ per hour which would imply a 40 hour work week.

The current methods seem to give far too much leeway to cherry picking which employees are "representative" of the median. While this may be more complicated up front, a consistent set of rules will make for a more straightforward approach and little confusion. As all of the compensation should already be reported to the IRS, there is little excuse for not doing so. The only parts which may need clarification would be the perks when considering how much the company private jet, or appartment, or chauffeur, or other non standard potentially timeshared items are. An assumed standardized cost could be created for them to use for such items and would be the same across all companies allowing for a simpler and much more meaningful comparison.